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In re S.O.
Amanda O. (mother) suffers from a severe mental disorder. Due to manifestations of that illness, her daughter S.O. was removed from her custody shortly after the child's birth. Two months after reunification services were ordered, mother began a new drug treatment and responded positively. At the six-month review hearing, however, mother did not oppose the termination of services and instead sought to have the child placed with the maternal grandmother. After the juvenile court denied the request and scheduled a permanency planning hearing (Welf. & Inst. Code, § 366.26),[1] mother filed a modification petition seeking reinstatement of reunification services (§ 388) on the ground that her mental condition had improved to the point she could now comply with her case plan. The court denied the petition and proceeded to terminate mother's parental rights and select adoption as S.O.'s permanent plan. Mother now appeals.

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